Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Entitlement to compensatory interest on delayed customs refunds arises under Section 27A and the statute mandates interest from the day after three months from receipt of the refund application; a deeming fiction in law does not postpone that commencement. The Department's wrongful rejection and protracted adjudication cannot defeat this statutory right, and denial of interest on the ground that refund was sanctioned only after appellate orders is unsustainable. Consequently the appellant is entitled to interest from the expiry of three months from each original refund application date in 2003 until actual payment, and the adjudicating authority was directed to compute and pay it promptly.
Entitlement to compensatory interest on delayed customs refunds arises under Section 27A and the statute mandates interest from the day after three months from receipt of the refund application; a deeming fiction in law does not postpone that commencement. The Department's wrongful rejection and protracted adjudication cannot defeat this statutory right, and denial of interest on the ground that refund was sanctioned only after appellate orders is unsustainable. Consequently the appellant is entitled to interest from the expiry of three months from each original refund application date in 2003 until actual payment, and the adjudicating authority was directed to compute and pay it promptly.
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